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of 19 Keynote AP17 WV & FoD Bat SAC – August 2015


Purpose:

This evidence paper has been developed to provide some context as to the Forest of Dean District

Council Allocations Plan (AP) and the Wye Valley and Forest of Dean Bat SAC (Bat SAC). It provides

further background information in supporting the AP Habitats Regulations Assessment (HRA).

The AP HRA

There are no site allocations close enough to the Bat SAC which would cause direct impact. Direct

disturbance as a result of the AP is therefore considered unlikely (AP HRA1). The HRA made a series

of policy amendments (avoidance/cancelation measures) in relation to the Bat SAC to a number of

polices. Table 1 below provides some additional context to sites identified in the HRA where it was

considered appropriate to include cancellation or avoidance requirements in regards to the Bat SAC.

Table 1 provides additional information and needs to be read in conjunction with the AP and HRA. It

should also be remembered the approach to the AP policies is on a precautionary basis.

In addition to site or individual policy assessment the HRA looked strategically at the overall

quantum and location of development in relation to the Bat SAC. This analysis was undertaken

spatially and now provided in Annex A. The process involved considering those AP policies where

there was theoretical potential for disturbance to the Bat SAC, in light of the cancelation and

avoidance requirements and, in the context of the SAC sites and other employment and housing

allocations. Horseshoe bat roost records (held by Gloucestershire Centre for Environmental Records)

were included, extracts for the four main towns are included in Annex A.

The assessment was undertaken by a group of officers from the council with in-depth knowledge of

the District, the SAC and planning proposals. In considering whether allocations had the potential to

have likely significant effects the group considered a range of factors including the proximity of

allocations to SAC’s and other know SAC feature sites; intervening topography and land cover

between allocations and SAC sites; features on and adjacent to allocation sites; appropriate bat

mitigation approaches and relationships between allocations. The group took account that some

allocations, which may have current or previous planning permission may not have been subject to a

review of consent with regards to the Habitats Regulations.

Conclusions

No direct impacts on the Bat SAC have been identified. On a precautionary basis where AP polices

/allocations where identified as having some theoretical potential for disturbance to the Bat SAC the

local site context and development policy proposals have been considered. In all cases it has been

considered that cancellation and avoidance measures can be easily incorporated to remove the

potential for disturbance to the SAC; bearing in mind the local site /policy context.

At strategic level, bearing mind only a small percentage of sites /polices were considered to have

theoretical potential to result in disturbance to the Bat SAC, the spatial distribution of all the housing

and employment allocations was considered. This was undertaken in the light of the general

1 Draft for council 26

th February 2015


development requirements of the NPPF and Core Strategy policy 12. The conclusion of this

assessment is that due to the distribution, the local landscape context and the relatively small scale

development proposals there would be no residual effects of the AP on the Bat SAC.

2 The Councils validation checklist requires all ‘major’ development proposals to have completed a Preliminary

Ecological Appraisal (CIEEM) as an ecological minimum for an application to be validated.


Table 1

Policy Site Photo (Where applicable)

Site Context & Characteristics

Cancelation and Avoidance measures

AP 17 – Land at Stowfield, Lydbrook.

Large scale former industrial site. In planning terms the site has existing employment use although not currently in use.

Owner has undertaken a number of scoping studies including a Phase 1 Habitat assessment

Adjacent to a number of Designations

Potential for land contamination issues

Redevelopment of the land at Stowfield will be supported by the Allocations Plan but only where: • The environmental impacts can be

shown to be acceptable and • The development proposed will not be

subject to unacceptable flood risk, • There will be no adverse effects on

European nature conservation designations,

• Development will not be adversely affected by any legacy including contamination from the past uses and

• Clear benefits to the AONB can be demonstrated.

Special requirements: Proposals should be of a high standard providing a unique sense of place. Masterplan and development to be fully compatible with Wye Valley Woodland SAC, River Wye SAC Wye Valley and Forest of Dean bat SACs. Must take full account of and be compatible with AONB designation. Proposals will need to be prepared and considered in relation to the Habitats Regulations


AP 26 – Additional Cycle Connections

Not site specific policy Not site specific policy.

General promotional policy to support proposals.

Expectation is that majority of routes will be on existing Forest roads on Forestry Commission land.

Development will only be permitted where it can be demonstrated that it will not have an adverse effect on the integrity of any designated SAC, SPA or Ramsar sites

AP 27 – Lydney to Parkend Cycle route

Specific route not defined Not site specific policy.

General promotional policy to support proposals.

Expectation is that majority of routes will be on existing Forest roads on Forestry Commission land.



AP 29 –Wye valley

Former rail bed (largely overgrown) in Wye Valley woodland including a tunnel section.

Tidenham Tunnel is known to provide roosting for horseshoe bats.

Allocation has be subject to HRA in the past (P1626/10/FUL) and subsequently cycleway permitted.

Examples of similar schemes working elsewhere e.g Bath



AP 42 –Lydney Harbour

Site within Environment Agency ownership.

Adjacent to Severn estuary SAC Historic value (SAM & Listings). Existing formal and informal recreational access.

Footpath and road connection. Open free car parking

Requirements for proposals to be subject to their compatibility with the safeguarding and enhancement of the harbour as an historic feature, the conservation status of the estuary and their compatibility with the Habitats Regulations. The Special requirements as set out in Appendix “Lydney European Sites” apply ”

AP 43 – Pine End Works

Large scale former industrial site.

In planning terms the site has existing employment use although not currently in use.

Within 100m of Severn Estuary

All proposals will need to take full account of the conservation status of the estuary and be compatible with the Habitats Regulations. Special requirements as set out in the appendix “Lydney European Sites” are likely to apply


AP 44 – Lydney Industrial Estate

Existing large scale industrial estate with a range of light industrial, storage and engineering uses.

Within 100m of Severn Estuary


AP 46 - Lydney harbour Area Cycling and Walking

Not site specific policy Not site specific policy. General promotional policy to support proposals. Expectation is that majority of routes will be using existing PROW or addressing ‘missing links’.



AP 47 East of Lydney

Agricultural area adjacent to residential areas of Lydney

Has existing planning permission for residential development. Many applications over the last 10 years. The most resent being for the northern section (P0361/15/OUT) which was subject to HRA. Substantial development in the southern section has taken place (P0627/13/FUL) which included mitigation for a LHB roost.

1.5 km from Severn

Provides for linear GI following central watercourse and open space

Planning permissions subject to HRA previously



AP 51 - Railway Station Area (Lydney)

Existing railway, car parking uses.

Development proposals must demonstrate that the treatment of waste water and any run off can be adequately provided for and that no adverse effects on the integrity of the River Severn SAC, SPA and Ramsar sites result.


AP 52 -Land North of Mainline Railway (Lydney)

Former tip site

Current open informal recreational access

Under the ownership of Lydney Recreational Trust

Key wildlife site (Open mosaic grassland)

New uses will need to demonstrate suitable management and protection of the wildlife contribution of the area


AP 53 - Holms Farm (Lydney)

Largely abandoned farm complex.

Existing Farm house in use

Known LHB roost

Outline consent for development (P1325/06/OUT) (NE confirmed appropriate mitigation could be achieved).

Allocated in 2005 local plan

Adjacent to existing residential areas

Development will only be permitted where it can be demonstrated that it will not have an adverse effect on the integrity of the Wye Valley and Forest of Dean Bat SAC


AP 90 - Land North of Newnham on Severn

Agricultural grassland fields

Adjacent to school and recreation fields

Development will only be permitted where it can be demonstrated that it will not have an adverse effect on the integrity of the Wye Valley and Forest of Dean Bat SAC


Annex A

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